Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:00-cv-00129-FMA

Document 74

Filed 09/02/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LOCKHEED MARTIN CORPORATION, ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. )

No. 00-129C (Judge Allegra)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the United States Court of Federal Claims, counsel for plaintiff respectfully moves for an enlargement of time of 7 days, to and including September 9, 2004, within which to file its Motion for Summary Judgment. Accordingly, counsel for plaintiff further moves for an enlargement of time of 7 days, to and including October 21, 2004, for filing of defendant's Cross-motion for Summary Judgment. The dates for filing such motions have been enlarged one time. Plaintiff requires the requested time extension because the individual whose Declaration must accompany Plaintiff's Motion for Summary Judgment is unable to complete his Declaration until next week. He lives and works in Orlando, Florida, and has been taking steps to protect his home and family from the approaching Hurricane Frances.

Case 1:00-cv-00129-FMA

Document 74

Filed 09/02/2004

Page 2 of 2

Today counsel for plaintiff discussed this motion with counsel for defendant, and she has no objections to this motion. Respectfully submitted,

_________________________________ Clarence T. Kipps, Jr., Esq. MILLER & CHEVALIER Chartered 655 15th Street, N.W., Suite 900 Washington, D.C. 20005 Tel: (202) 626-5800 Fax: (202) 628-0858 Attorney of Record Lockheed Martin Corporation Of Counsel: Angela B. Styles, Esq. Kimberly R. Heifetz, Esq. MILLER & CHEVALIER Chartered 655 15th Street, N.W., Suite 900 Washington, D.C. 20005 Tel: (202) 626-5800 Fax: (202) 628-0858 David M. Christenson, Esq. LOCKHEED MARTIN CORPORATION 6801 Rockledge Drive Bethesda, Maryland 20817 Tel: (301) 897-6127 Fax: (301) 897-6333 Dated: September 2, 2004

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